Last updated: February 25, 2022
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data: While you use my website, I may ask you to provide me with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Mailing address
- Brokerage name and location
- Web address
- Professional title and/or credentials
- Credit card information in order to pay for products and/or services offered through my website
Usage Data: Usage data is collected automatically when using my website.
Usage data may include information such as your device’s internet protocol address (e.g. IP address), browser type, browser version, the pages of my website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access my website with a mobile device, I may collect certain information automatically, including but not limited to the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
I may also collect information that your browser sends whenever you visit my website or when you access my website with a mobile device.
- Web Beacons. Certain sections of my website and my emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit me, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Use of Your Personal Data
I may use your personal data for the following purposes:
To operate and maintain my website, including monitoring its usage.
To manage your user account on my website. The personal data you provide may give you access to different functionalities of my website that may be available to you as a registered user.
To fulfill your orders for products or services that you may have purchased through my website.
To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication to facilitate order processing or inform you of updates to policies, products, services, website features.
To provide you with news, special offers and general information about other goods, services, and events which I offer that are similar to those that you have already purchased or enquired about (unless you have opted not to receive such information).
For other purposes: I may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of my promotional campaigns, and evaluating and improving my website, products, services, marketing, and your experience.
I may share your personal information in the following situations:
- With service providers (employees or third-party companies) who process the data on my behalf to process payments, deliver services, or help me analyze how the website is being used.
- With other users when you share personal information or otherwise interact in the public areas with other users. Such information may be viewed by all users and may be publicly distributed outside.
- For business transfers: I may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of my business assets, financing, or acquisition of all or a portion of my business to another company.
- With your consent: I may disclose your personal information for any other purpose with your consent.
The service providers I use may have access to your personal data. These third-party vendors collect, store, use, process and transfer information about your activity on my website in accordance with their privacy policies.
Third-party Service Providers That I Use
I may use third-party service providers to monitor and analyze the use of my website.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of my website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
I may use your personal data to contact you with email updates, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from me by following the unsubscribe link or instructions provided in any email I send or by contacting me.
I may use email marketing service providers to manage and send emails to you.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
I may provide paid products and/or services within my website. In that case, I may use third-party services for payment processing (e.g. payment processors).
Usage, Performance and Miscellaneous
I may use third-party service providers to provide better improvement of my website.
I use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from you and from your device for security purposes.
Retention of Your Personal Data
I will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of my website, or I am legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including personal data, is processed at my operating office and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state/province/country, possibly in another governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, I may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
I may disclose your personal data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend my rights or property
- Prevent or investigate possible wrongdoing in connection with my website
- Protect the personal safety of users of my website or the public
- Protect against legal liability
Security of Your Personal Data
The security of your personal data is important to me, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While I strive to use commercially acceptable means to protect your personal data, I cannot guarantee its absolute security.
Your personal information is available to you in your profile that you created when registering as a user. Such information is available to you at any time to validate or correct errors.
Changes in practice
FOR CALIFORNIA RESIDENTS
Categories of Personal Information Collected
I collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
A consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
A device means any device that can access my website such as a computer, a cellphone or a digital tablet.
The following is a list of categories of personal information which I may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by me, but reflects my good faith belief to the best of my knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to me.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F: Internet or other similar network activity.
Examples: Interaction with my website or advertisement.
Category G: Geolocation data.
Examples: Approximate physical location.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
I obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, from the forms you complete on my website, preferences you express or provide through my website, or from your purchases on my website.
- Indirectly from You. For example, from observing your activity on my website.
- Automatically from You. For example, through cookies I or my service providers set on your device as you navigate through my website.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of my website, third-party vendors for payment processing, or other third-party vendors that I use to provide my website to you.
Use of Personal Information for Business Purposes or Commercial Purposes
I may use or disclose personal information I collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
- To operate my website and provide you with my website.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve my website.
- To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about my website, products, or services, I will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, I will use that information to process your payment and facilitate delivery.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how I use this information, please refer to the “Use of Your Personal Data” section.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
I may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When I disclose personal information for a business purpose or a commercial purpose, I enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that I may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
I may sell and may have sold in the last twelve (12) months the following categories of personal information:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
Share of Personal Information
I may share your personal information identified in the above categories with the following categories of third parties:
- Service providers
- Payment processors
- My affiliates
- My business partners
- Third party vendors to whom you or your agents authorize me to disclose your personal information in connection with products or services I provide to you
Sale of Personal Information of Minors Under 16 Years of Age
I do not sell the personal information of consumers I actually know are less than 16 years of age, unless I receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to me by contacting me.
If I have reason to believe that a child under the age of 13 (or 16) has provided me with personal information, please contact me with sufficient detail to enable me to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, you have the right to request that I disclose information to you about my collection, use, sale, disclosure for business purposes and share of personal information. Once I receive and confirm your request, I will disclose to you:
- The categories of personal information I collected about you
- The categories of sources for the personal information I collected about you
- My business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom I share that personal information
- The specific pieces of personal information I collected about you
- If I sold your personal information or disclosed your personal information for a business purpose, I will disclose to you:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of personal data (opt-out). You have the right to direct me to not sell your personal information. To submit an opt-out request please contact me.
- The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once I receive and confirm your request, I will delete (and direct my service providers to delete) your personal information from our records, unless an exception applies. I may deny your deletion request if retaining the information is necessary for me or my service providers to:
- Complete the transaction for which I collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of my ongoing business relationship with you, or otherwise perform my contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with me.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact me:
By email: email@example.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to me must:
- Provide sufficient information that allows me to reasonably verify you are the person about whom I collected personal information or an authorized representative
- Describe your request with sufficient detail that allows me to properly understand, evaluate, and respond to it
I cannot respond to your request or provide you with the required information if I cannot:
- Verify your identity or authority to make the request
- And confirm that the personal information relates to you
I will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures I provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, I will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
You have the right to opt-out of the sale of your personal information. Once I receive and confirm a verifiable consumer request from you, I will stop selling your personal information. To exercise your right to opt-out, please contact me.
The service providers I partner with (for example, my analytics or advertising partners) may use technology on the service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by my service providers by following my instructions presented on the service:
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform http://www.youronlinechoices.com/
- The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
My website does not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
My website does not address anyone under the age of 13. I do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided me with personal data, please contact me. If I become aware that I have collected personal data from anyone under the age of 13 without verification of parental consent, I take steps to remove that information from my servers.
If I need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, I may require your parent’s consent before I collect and use that information.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with me can request information once a year about sharing their personal data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact me using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact me using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
I have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
By email: firstname.lastname@example.org
Account means a unique account created for you to access my website or parts of my website.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the company as the legal entity that collects consumers’ personal information and determines the purposes and means of the processing of consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
Company (referred to as either “the company”, “I”, “me” or “my” in this Agreement) refers to Paul Cavanagh, 42 Gretna Green, London, ON N6G 1X1.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Country refers to: Ontario, Canada
Device means any device that can access my website such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.
Service Provider means any natural or legal person who processes the data on behalf of me. It refers to third-party companies or individuals employed by me to facilitate my website, to provide website on behalf of me, to perform services related to my website or to assist me in analyzing how my website is used.
Usage Data refers to data collected automatically, either generated by the use of my website or from my website infrastructure itself (for example, the duration of a page visit).
Website refers to Attract Downsizing Seniors, accessible from https://attractdownsizingseniors.com
You means the individual accessing or using my website, or the company, or other legal entity on behalf of which such individual is accessing or using my website, as applicable.